BAKER, C.J.
In this appeal, a local congregation [Olivet] that was a part of the national Presbyterian Church petitioned to leave the national Church. When the governing Church body [Presbytery] indicated that it might not permit the local congregation to retain the property on which it was situated, the local congregation truncated the process and refused to acknowledge the Church’s right to the property. The dispute made its way into the judicial system, and we now conclude that because (1) the local congregation was part of the national Church and accepted the benefits of being part of a national organization, (2) the local congregation acknowledged in its bylaws that it was bound by the national Church Constitution and could not amend its bylaws to conflict with that document, and (3) the Church Constitution contains a clause providing that all property titled to local congregations is held in trust for the use and benefit of the national Church, judgment must be entered in favor of the governing judicatory bodies of the national Church—the Appellants.
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. . . [T]he United States Supreme Court further explored the neutral principles approach in Jones v. Wolf, 443 U.S. 595 (1979). The Supreme Court cited the approach with favor in general, but noted certain difficulties as well:
The primary advantages of the neutral-principles approach are that it is completely secular in operation, and yet flexible enough to accommodate all forms of religious organization and polity. The method relies exclusively on objective, well-established concepts of trust and property law familiar to lawyers and judges. . . .
That is not to say that the application of the neutral-principles approach is wholly free of difficulty. The neutral-principles method . . . requires a civil court to examine certain religious documents, such as a church constitution, for language of trust in favor of the general church. In undertaking such an examination, a civil court must take special care to scrutinize the document in purely secular terms . . . .
On balance, however, the promise of nontanglement and neutrality inherent in the neutral-principles approach more than compensates for what will be occasional problems in application. . . . We therefore hold that a State is constitutionally entitled to adopt neutral principles of law as a means of adjudicating a church property dispute.
Id. at 603-04 (emphasis added).
In this case, the trial court focused nearly exclusively on the language of the deed to the Oak Hill Property. Although the deed language is certainly a relevant consideration, that is not the end of our inquiry. This court has explained that the neutral principles of law approach “’requires courts to examine certain documents for language of a trust in favor of the General Church. The documents to be examined include civil statutes, the express language of deeds, local church charters, and general church constitutions.’” Hinkle, 469 N.E.2d at 43 (quoting Grutka v. Clifford, 445 N.E.2d 1015, 1019 (Ind. Ct. App. 1983)).
In Merryman, this court implied that a trial court may not examine church documents in applying the neutral principles approach, stating that the only relevant inquiry is the language to be found in the deed itself. 147 Ind. App. at 312-13, 259 N.E.2d at 893. This so-called formal title approach, however, has not been the law of Indiana since the United States Supreme Court issued Jones in 1979. The Jones Court held that, in fact, trial courts are required to examine church constitutions and similar documents for trust language. 443 U.S. at 603-04. And this court later clarified, following Merryman, that so long as the analysis does not require ecclesiastical inquiries, examination of church charters and constitutions is appropriate under the neutral principles approach. United Methodist Church v. St. Louis Crossing Independent Methodist Church, 150 Ind. App. 574, 584-85 276 N.E.2d 916, 922 (1971).
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. . . [W]hat we are asked to do herein is resolve a property dispute. We have applied the neutral principles of law approach—as advocated for by Olivet—and have, consequently, applied principles of contract, corporate, and property law in interpreting Olivet’s bylaws and the property provisions of the PC(USA) Constitution. Just because a party states that a document or a specific provision of a document is ecclesiastical does not automatically make it so, and here, no ecclesiastical inquiry is necessary to resolve the dispute.
Olivet agreed to be a part of the PC(USA) when it was formed in 1983. By so agreeing, Olivet reaped the myriad benefits of being affiliated with a national organization. Olivet amended its bylaws in 1998 and 2000, on both occasions acknowledging that it was bound by the PC(USA) Constitution and that it could not amend its bylaws to conflict with that document. Included in the PC(USA) Constitution is the non-ecclesiastical Property Trust Clause—the validity of which Olivet does not dispute—providing that all property titled in the name of individual congregations is nonetheless held in trust for the benefit of the PC(USA). When Olivet decided to leave the PC(USA), it did so by following the procedures set forth in the PC(USA) Constitution—at least until the Presbytery indicated that it might not permit Olivet to retain the Oak Hill Property. At that point, Olivet truncated the process, indicated its refusal to abide by the Presbytery’s decision, and forced the Appellants to turn to the judicial system to resolve the dispute. Under these circumstances, having applied neutral principles of law and treated these parties and their property dispute as any other corporate entities who appear before us, we can only conclude that the trial court erred by entering summary judgment in Olivet’s favor. [Footnote omitted.]
NAJAM, J., and MATHIAS, J., concur.